Massachusetts Injury Lawyers Blog
A denial of Social Security disability benefits can feel devastating, but federal court review may still offer a path forward. A recent decision from a Massachusetts court shows that when an Administrative Law Judge does not adequately explain how medical opinions are weighed, remand is required. If you are appealing a Social Security disability denial, it is smart to speak with a Massachusetts disability attorney promptly to determine how you can protect your interests.
Case Setting
The plaintiff allegedly filed a Title II application in December 2020, alleging disability beginning in January 2020. The claim was initially denied, and upon reconsideration, the plaintiff requested a hearing. An Administrative Law Judge conducted a telephonic hearing in October 2022 and issued an unfavorable decision in November 2022. The Appeals Council denied review, and the plaintiff then filed the federal complaint in October 2024.
It is alleged that the record included treatment beginning in 2020 for cervical and hip complaints, conservative management with medications and injections, and opinions from both an impartial medical examiner and state agency consultants. Of particular note, an examining pain specialist opined that the plaintiff was permanently partially disabled and set functional limits on standing and walking that were more restrictive than the state agency assessments.
It is reported that the ALJ found severe impairments, including anxiety, depression, degenerative disc disease, a left hip impairment, and obesity, but determined the impairments did not meet or equal a Listing. The ALJ assessed a light-work residual functional capacity with six hours each of sitting, standing, and walking, along with postural and hazard limitations, and concluded at step five that significant jobs existed in the national economy that the plaintiff could perform.
It is alleged that the district court recited the familiar substantial evidence standard under § 405(g) and emphasized that while the threshold is not high, findings must rest on relevant evidence a reasonable mind might accept. The court also explained that legal error or inadequate articulation permits remand even where the record contains substantial evidence.
It is reported that the plaintiff sought judicial review under 42 U.S.C. § 405(g) after an unfavorable administrative decision that denied disability insurance benefits. The defendant, the Commissioner of Social Security, moved to affirm, and the parties fully briefed cross-motions based on the administrative record.
How the Court Evaluated the ALJ’s Opinion Evidence
It is reported that the plaintiff argued the ALJ failed to perform the “supportability” analysis required by 20 C.F.R. § 404.1520c when discounting the impartial examiner’s opinion, particularly the standing and walking limitations of three to four hours standing and two to three hours walking. The Commissioner countered that the ALJ’s discussion implicitly addressed supportability and that any error was harmless because the residual functional capacity would have been the same.
The court drew a sharp distinction between the two core factors in weighing medical opinions. “Consistency” is an outward comparison to the rest of the record, while “supportability” is an inward look at the objective evidence and explanations supplied by the source. The court found the ALJ’s analysis of the impartial examiner lacked any discussion of the examiner’s methodology, examination findings, or explanations, and therefore failed to articulate supportability as the regulation requires.
The court concluded the omission was not harmless. The ALJ’s residual functional capacity assumed up to six hours each of standing and walking, while the impartial examiner limited standing to three to four hours and walking to two to three hours. That difference could reasonably alter vocational expert testimony and the step-five outcome. Because the reviewing court could not trace the ALJ’s reasoning regarding supportability, remand under sentence four of § 405(g) was required.
The court rejected a parallel challenge to the state agency consultants. Unlike the discussion of the impartial examiner, the ALJ’s narrative tied the consultants’ assessments to objective findings such as normal gait, mild imaging, and reported improvement with treatment, which sufficed to show an implicit supportability analysis under First Circuit authority. Thus, the court held there was no legal error in the treatment of those opinions.
The court granted the plaintiff’s motion for judgment on the pleadings to the extent of remanding for further proceedings, denied the Commissioner’s motion to affirm, and entered judgment for the plaintiff. The decision reinforces that adjudicators must do more than declare an opinion “partially persuasive.” They must explain how the medical source’s own evidence and reasoning support or fail to support the offered limitations, especially when the limitations could be outcome-determinative at step five.
Consult a Skilled Massachusetts Social Security Disability Attorney
If you received an unfavorable decision on your disability claim, careful attention to the ALJ’s articulation of supportability and consistency can make the difference on appeal. James K. Meehan of the Law Office of James K. Meehan is a skilled Massachusetts social security disability lawyer who can evaluate your record, identify legal errors, and pursue remand or reversal where appropriate. You can contact Mr. Meehan by calling 508-822-6600 or by filling out the online form to arrange a consultation.